July 2018

IRS Actively Targeting Taxpayers for Passport Denial/Revocation – Notice CP508C

2018-12-08T22:18:40+00:00

By: Eli S. Noff, Esq., CPA, Partner & Mary Lundstedt, Esq., Associate Several news outlets this week report that the U.S. State Department confirms that it has already acted on its part in the process and denied passports to an undisclosed number of taxpayers. Reports also confirm that the IRS [...]

IRS Actively Targeting Taxpayers for Passport Denial/Revocation – Notice CP508C2018-12-08T22:18:40+00:00

United States V. Garrity: Clarifies Standard of Proof and Establishing Willfulness in FBAR Context

2018-12-08T22:20:05+00:00

By: Eli Noff, Partner and Mary Lundstedt On April 3, 2018, in United States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government's suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of [...]

United States V. Garrity: Clarifies Standard of Proof and Establishing Willfulness in FBAR Context2018-12-08T22:20:05+00:00

I.R.C. §280E: A Buzzkill For Those Who Keep Poor Records

2018-12-06T08:18:39+00:00

By: Eli S. Noff, Partner & Mary Lundstedt The recent Tax Court's Alterman v. Commissioner[1] decision is a lesson in Accounting 101 for Cannabisseurs. Well, technically it's a valuable lesson about record-keeping to all taxpayers who are subject to Internal Revenue Code (I.R.C.) §280E-but with the currently high audit rates for the marijuana industry, [...]

I.R.C. §280E: A Buzzkill For Those Who Keep Poor Records2018-12-06T08:18:39+00:00

Virtual and Economic Contacts Establish Nexus for Sales Tax

2018-12-06T08:44:40+00:00

By: Eli Noff, Partner & Mary Lundstedt On June 21, 2018, the Supreme Court delivered its highly anticipated decision in South Dakota v. Wayfair, Inc., et al.[1] The 5-4 decision discards the antiquated "physical presence rule" - a rule which has allowed retailers lacking a physical presence in a state to avoid any obligation [...]

Virtual and Economic Contacts Establish Nexus for Sales Tax2018-12-06T08:44:40+00:00

June 2018

Howeycoin – Too Good to be True

2018-12-06T08:17:14+00:00

By Mary Lundstedt "If you’ve ever been tempted to buy into a hot investment opportunity linked with luxury travel, the Securities and Exchange Commission has a deal for you." Sound too good to be true? It is. This announcement was made in the May 16, 2018 U.S. Securities and Exchange Commission [...]

Howeycoin – Too Good to be True2018-12-06T08:17:14+00:00

IRS Responds to States’ Attempts to Circumvent SALT Cap

2018-12-06T08:30:04+00:00

By Mary Lundstedt On May 23, 2018, the IRS issued Notice 2018-54,[1] making it abundantly clear that when it comes to state efforts to circumvent the recently enacted state and local tax (SALT) deductions cap, "taxpayers should be mindful that federal law controls the proper characterization of payments for federal income [...]

IRS Responds to States’ Attempts to Circumvent SALT Cap2018-12-06T08:30:04+00:00

District Court Maintains $100,000 Regulatory Cap For Willful FBAR Violations

2018-12-06T08:07:29+00:00

By Eli Noff, Partner & Mary Lundstedt, Esq. On May 16, 2018, in United States v. Colliot,[1] the District Court for the Western District of Texas held that the Internal Revenue Service (IRS) is precluded from assessing a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty exceeding the $100,000 [...]

District Court Maintains $100,000 Regulatory Cap For Willful FBAR Violations2018-12-06T08:07:29+00:00

The IRS is Receiving Thousands of Coinbase Users’ Information

2018-12-08T22:23:57+00:00

By Mary Lundstedt , Esq. In November of 2017, Coinbase, Inc. ("Coinbase"), a company that facilitates digital currency transactions, was ordered to comply with an IRS summons demanding specific Coinbase client identifying information and transaction data for Coinbase accounts "with at least the equivalent of $20,000 in any one transactions type" [...]

The IRS is Receiving Thousands of Coinbase Users’ Information2018-12-08T22:23:57+00:00

May 2018

Notice CC-2018-005: How Chief Counsel Attorneys Handle Passport Actions

2018-12-08T22:23:31+00:00

By Mary Lundstedt, Esq. On April 5, 2018, the Chief Counsel's Office provided advice in Notice CC-2018-005 to Chief Counsel attorneys who handle I.R.C. §7345 passport actions. The Chief Counsel's Office detailed both the certification and reversal processes for "seriously delinquent taxpayers," as well as the procedures for the judicial [...]

Notice CC-2018-005: How Chief Counsel Attorneys Handle Passport Actions2018-12-08T22:23:31+00:00

Baltimore Police Commissioner De Sousa Charged With Tax Crime

2018-12-06T08:00:39+00:00

By Mary Lundstedt, Esq. On May 10, 2018, the United States Attorney for the District of Maryland announced that new Baltimore Police Commissioner Daryl De Sousa has been charged with three misdemeanor counts of willful failure to file a U.S. individual income tax return. Specifically, the charges allege that Commissioner De [...]

Baltimore Police Commissioner De Sousa Charged With Tax Crime2018-12-06T08:00:39+00:00
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